In September 2025, ACEEE submitted comments to the Colorado Department of Public Health and Environment (CDPHE) on the Colorado Greenhouse Gas Emissions and Energy Management for Manufacturing (GEMM) Phase 2 facility draft plans, which can lower energy use and reduce greenhouse gas (GHG) emissions through widespread adoption in the state. ACEEE provided general comments on facility plans which centered on consistency across plans with respect to carbon price benchmarking and validation, impact evaluation for disproportionately impacted and residential communities (DICs), suggestions for additional metrics, programs, funding sources for compliance, and additional resources for emerging technologies, thermal re-design, electrification, and industrial heat pumps. ACEEE also provided specific comments on eight (8) Phase 2 draft facility plans that were submitted to the state.
ACEEE Comments to CDPHE on GEMM 2 Plans Sept 2025
ACEEE also submitted joint comments to CDPHE with the Sierra Club. These comments focused on support for elements of the existing GEMM 2 rule (mass-based reductions, prioritizing onsite reduction strategies, including a broad range of facilities and requiring facility GHG reduction plans), while offering input on potential areas of improvement to ensure consistency across plans (considering all technically feasible options, more uniform application of economic impact analyses, evaluation of co-pollutant benefits and alignment of long term planning with state-wide climate targets). The joint submission also offered plan-specific comments for eight (8) Phase 2 draft facility plans that were submitted to the state.
